Class hopping

The last couple of years have given shape to a complex regulatory landscape, with the UN's Globally Harmonised System of Classification and Labelling or Chemicals (GHS) being implemented in a number of countries, the EUs Registration, Evaluation. Authorisation and Restriction or Chemicals (REACH) regulatory framework being enforced, the anticipated reform of the Toxic Substance Control ACT (TSCA) in the US. and a number of changes in the chemical inventory area in some Asian countries, all taking centre stage.

GHS and REACH in particular have become essential components of corporate account globalisation plans, with their impact being felt throughout the entire chemical lifecycle and global supply chain. Many countries have implemented GHS, but not always in its entirety, which results in difference in how the classification results are presented on both the Safety Data Sheet (SDN) and on labels. In Europe, companies will be required to follow a mandatory harmonised classification or certain substances for certain endpoints. Korea and Japan also have official lists of recommended CHS classifications for substances.

As much as GHS is meant to drive global harmonisation. individual countries .ire allowed to select the physical hazards, the health and environment classes and the associated categories within each class that they wish to .adopt. and most countries that have implemented GHS have chosen to keep some of their existing hazard classification and communication that is not vet pan of the GHS. As a result, there will be far less harmonisation between countries and regulatory authorities within each country than originally anticipated.

The UN GHS system provides the basic framework for the harmonised hazard classification of chemical substances and mixtures and for a harmonised way of communicating the hazard via labels and SDSs. The introduction of GHS in a country requires companies to not only reclassify all chemicals and to re-author and re-distribute all SDS documents and labels, but also involves a massive training requirement for all users of chemicals as well as o( the enforcing authorities.

Many so-called downstream regulations are based on the hazard classification of chemicals and when the classification system changes the chemicals that ate impacted by these downstream regulations have to be re-assessed. Examples of such downstream regulations are the EU Seveso Directive and the EU workplace directives dealing with the use of chemicals in the workplace.

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